At Hyphenate Life Limited t/a S’able Labs we are committed to respecting your privacy and protecting the personal information that we obtain and hold about you and others.
Question Information in Response
What kind of personal data do we collect about
We might collect data from and about you only when it is relevant and proportionate to do so, in particular the Company may collect (1) registration data, (2) public data and posts, (3) data that you have permitted social media to share with the Company and (4) activity data. We do not currently collect either financial information from a payment service provider or sensitive data relating to you. For further information, please go to paragraph 2 (a)
How do we use your personal data?
The main reason why we collect data about you is to provide you with Company Services, to analyse the Company Services and to allow you to interact with those services. In addition, with your prior consent, we can send you offers, promotions and marketing communications, also based on your personal preferences and habits. For further information, please go to paragraph 2
On what basis do we use your personal data?
Your personal data is mainly collected to provide you with Company Services.
Your personal data is also necessarily collected to comply with legal obligations or to pursue the legitimate interests of the Company. If you don’t provide the data we may not able to offer you the Company Services. When your personal data is collected for marketing purposes, you have the option not to provide the Company with your personal data.
Who can access to your personal data? We might share your personal data with: (i) service providers; (ii) our affiliated companies; and (iii) national authorities, when allowed by the applicable laws.
What are your rights with regard to your personal
You have a number of rights with regard to your personal data and these include the right to access, complete, update, amend and delete your personal data. For further information, please go to paragraph 4.
How do we process your personal data?
The security of your data is a priority for us. We have implemented adequate administrative, technical and physical measures designed to safeguard your personal data against loss, theft and unauthorised use, disclosure or modification. For further information, please go to paragraph 6.
Is your personal data transferred abroad?
Your personal data might be transferred to other countries within or outside the European Economic Area. We always make sure that appropriate and suitable safeguards compliant with applicable laws are in place to protect your personal data. For further information, please go to paragraph 7.
Retention period applying to your personal data
The personal data we collect is retained for only for the period necessary to fulfill the purposes for which that data is collected. For further information, please go to paragraph 8.
How can I contact you with regard to the
processing of my personal data? You can contact us at the following email DPO@sablelabs.co
1. Introduction and General Terms
Hyphenate Life Limited, a company registered under company number 11855660 with registered address at 10 Queen Street Place, London, EC4R 1AG (“S’able”, “we”, “us” or “our” in this policy), works closely with emerging and upcoming talent to produce scripted and non-scripted film, television and digital content (“Services”).
Where we decide the purpose or means for the processing of the personal data that you provide when using our Website, we are the “data controller” for the purposes of the General Data Protection Regulation 2016 (“GDPR”) and the UK Data Protection Act 2018.
2. How We Use Your Personal Data
(a) Contacting Us (Your Enquiries, Requests and Submissions)
If you contact us via our Website ‘Contact’ webpage about our Services, to make an enquiry (such as in relation to project work or employment in our company or for any other purposes, the webpage asks you to provide a limited amount of personal information about yourself, such as your name, email address, subject (e.g. purpose of your message) and your message or enquiry. We will use this information to respond to your enquiries, for example:
· In line with the legitimate interest we have in promoting our business, we will process your enquiries to reply to your query, including providing you with information about the Services we offer.
· We may also respond to your enquiries or requests by taking steps in relation to your specific query or request, such as providing materials about some of our diversity and inclusion initiatives and opportunities, the festivals which we support and are involved in, or entering into an agreement to provide you with our Services.
You are under no obligation to provide us with any details, but if you choose to not provide us with relevant information, we may not be able to respond and/or provide the assistance that you request.
(b) Marketing and advertising
If you opt in receive information about our projects and services and for your email and social media usernames to be used to generate and provide you with social media advertising related to us, we may use your email address, social media usernames and (where specified) your phone number (and other personal information such as your name, age category and general location required to administer your opt in) to:
(i) send you emails with information about our other productions, products, projects and services;
(ii) contact you by phone or email about other relevant opportunities; and
(iii) use your email or social media usernames to provide you with specific advertising related to us that we think you may be interested in on other platforms such as Facebook, Instagram, Twitter, Snapchat and Google and/or to enable those other platforms to provide advertising related to us on our behalf to types of audiences who use those platforms. If we use your email or social media usernames in this way we remain the Data Controller of your information and the relevant platform does not have the right to use your email and/or social media usernames (provided by us in this way) for its own purposes. If you would like further information about how this works please refer to the privacy information provided by the social media platforms you use.
You can unsubscribe to marketing and advertising on our Website by either emailing DPO@sablelabs.co or using the unsubscribe option in any of the marketing emails that you receive or (if you are contacted by phone) telling us you no longer wish to be contacted.
(c) All content you submit to us
If you send us objectionable content, content that does not belong to you (plagiarised content) or otherwise behave in a disruptive manner when using our website, we may process personal data included in your messages to respond to and stop such behaviour.
· We only process personal data in this way for the legitimate interests of ensuring that use of our Website is lawful, does not disrupt our systems, does not harass our staff or other individuals, and to enforce our legal rights and to comply with our legal obligations.
· Where we reasonably believe you are or may be in breach of the law (for instance, because content you send amounts to harassment or is defamatory), we may use your personal information to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.
· Where we process personal data in this way, we will hold that personal information on our systems for as long as is reasonably necessary to achieve these objectives.
(d) Information obtained from Third Parties
We may obtain and store personal information about you that we collect from third parties (including our talent, booking and PR agents, trade bodies, forums, associated companies, or community groups) or social media websites (such as Twitter, LinkedIn, Facebook and/or Instagram) for the legitimate interest of carrying on our business. We do so to enable us to improve our communications and reach out to the optimum audience in order to make our initiatives and projects a success for S’able, our partner organisations and supporters and for the undiscovered talent that we seek to support.
If we do receive any personal information about you from these third parties, including the social media platforms, we will not process your information for the purposes of direct marketing unless you have provided your consent, or it is otherwise lawful for us to do so.
If you would like us to delete the personal information that we have received about you from these social media sites, please email us at DPO@sablelabs.co If you do not want us to receive further information about you from these sites, you should contact the sites directly to turn off the ‘follow’ setting.
We may occasionally collect special categories of personal data (i.e. more sensitive personal data) about you. If and when we do so, we will ensure that we do so under a lawful basis which may require obtaining your prior consent to collect (and share) this information.
3. Do We Share Your Personal Data with Anyone Else?
We only permit them to process your personal data for specified purposes and in accordance with our instructions. All our third party service providers are required to take appropriate security measures
to protect your personal information in line with our policies. Activities which are carried out by or in collaboration with third party service providers include talent provision, public relations, website hosting and our IT support.
In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the information we hold may be included as part of that sale, in which case you will be notified via email and/or a prominent notice on the Website of any changes in ownership or use of your information, as well as any choices you may have regarding that information.
Except as provided above, we will not provide your information to third parties.
4. Your rights in relation to your personal data which we process
You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests by you:
· for a copy of data we are processing about you and/or to have inaccuracies corrected;
· to restrict, stop processing, or to delete your personal data;
· for a machine readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
· to make a complaint to a data protection regulator. You may contact them at: https://ico.org.uk/concerns/
To make a request in relation to any of the aforementioned rights, please send your requests to DPO@sablelabs.co or write to our Data Protection Team at 10 Queen Street Place, London, EC4R 1AG.
We do not use the Website to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at DPO@sablelabs.co. We will delete such information within a reasonable time.
We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our website and services, taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Website visitors.
In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal information transmitted, stored or otherwise processed by us.
Please be aware that, while we make the security of our Website and your personal information a high priority and devote considerable time and resources to maintain robust IT security, no security
system can prevent all security breaches. When you choose to share your personal information with us, you accept the aforesaid and provide your information at your own risk.
7. International Data Transfers
Our servers are located in the European Union and the information that we collect directly from you will be stored in these servers. We may also transfer your personal data to members of our third party service providers, many of whom may be located outside of the EU, operate from multiple locations including non-EU based operations or engage sub-processors located outside the EU.
There are agreements in place with all of our third party service providers, including our talent and PR agents in the United States, to ensure that those parties process personal data using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and approved by the European Commission, such as the European Commission’s standard contractual clauses.
If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this policy, please let us know by emailing us at DPO@sablelabs.co.
To find out more about the standard contractual clauses, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en
8. Retention Periods or Criteria
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
If you would like us to stop using or holding your personal information and/or would like to request its deletion, please email us at DPO@sablelabs.co.
This Policy may be updated from time to time. We will notify you of any changes by posting the new policy here and, where feasible, by letting you know by email.
10. Contact Us
Questions, comments and requests in relation to this Policy are welcome and should be addressed to DPO@sablelabs.co. http://www.sablelabs.co/privacy-policy